Key Takeaways:
HTX has been rotating its wallet infrastructure across four blockchains every few hours since the UK sanctioned the exchange in May, according to blockchain intelligence firm TRM Labs.
Ari Redbord, global head of policy at TRM Labs, said the exchange's on-chain response turns its infrastructure into a continuous moving target that static address lists cannot track.
"HTX is changing its wallets every few hours to stay a step ahead of screening built on static lists," Redbord said.
The UK Foreign, Commonwealth and Development Office designated Huobi Global SA, the entity behind HTX, on May 26 under the Russia Sanctions Regulations for allegedly moving about $1.5 billion for Kremlin-aligned entities. TRM said the exchange retires hot wallets and funding addresses on regular cycles across TRON, Ethereum, BNB Smart Chain and Solana, with each address replaced within hours.
The tactic mirrors how sanctioned entities adapt to enforcement. After Garantex was disrupted in a March 2025 multinational takedown, its operators activated a pre-positioned successor called Grinex and migrated liquidity through the ruble-pegged stablecoin A7A5. HTX has adapted differently — rebuilding its on-chain infrastructure rather than rebranding — but with the same intent of staying operational.
TRM said behavior-based attribution can identify new wallets as they come online by recognizing on-chain activity patterns rather than matching against a fixed address list. The firm's Wallet Screening product checks counterparties against this behavioral model, catching new wallets as they appear.
The UK's Office of Financial Sanctions Implementation requires UK-regulated firms to freeze assets tied to HTX and report any exposure. The US Treasury's Office of Foreign Assets Control and the European Union have not designated the exchange, meaning obligations depend on jurisdiction. TRM advised compliance teams to run look-back exercises for pre-designation exposure and apply enhanced due diligence to fiat-pegged tokens with opaque governance.
The development follows broader UK regulatory pressure on HTX. In February, the Financial Conduct Authority began legal proceedings against the exchange for allegedly publishing unlawful financial promotions. An HTX spokesperson said in May that regulatory compliance remains a top priority and that the exchange monitors regulatory frameworks in all jurisdictions where it operates.
This article is for informational purposes only and does not constitute investment advice.
